Barnes v. Felix: The Supreme Court Reaffirms “Totality of the Circumstances” Review in Use-ofForce Cases

The US Supreme Court case, Barnes v. Felix, decisively settles a circuit court split by reaffirming that courts must evaluate police uses of force under the totality of the circumstances, as viewed from the perspective of a reasonable officer on scene. By rejecting the narrow “moment of threat” doctrine, the Supreme Court has ensured that courts can fully consider the broader context of an encounter, including events leading up to the use of force. This approach supports a more accurate, fair, and realistic assessment of officer conduct — one that recognizes both the challenges of policing and the importance of accountability under the Fourth Amendment.